Privacy Policy

1. Background and Scope

In 2020, ETC Group established this Privacy Policy (this Policy) to govern how we deal with data protection, privacy and associated issues, including how we may process your Personal Data. Supporting this Policy are certain other documents as referred to in section 10 of this Policy.

This Policy was developed with a view to applicable law in the United Kingdom, but it applies to the business wherever conducted, and may be supplemented from time to time with provisions that are applicable in specific jurisdictions. Except where expressly stated to the contrary, this Policy applies to all legal entities forming part of ETC Group, and to all of its personnel and staff, including directors, officers, employees and contractors of any such legal entity.

In this Policy, we use terms like “we”, “us”, “our” and the “business”, to refer to ETC Group generally as a business; these references are not limited to specific legal entities in ETC Group. When we refer in the policy to “you”, we mean any person (including legal entities) who we deal with in the course of our business. Other important defined terms used in this Policy document, such as “GDPR” and “Personal Data”, are detailed under section 12, “Definitions”.

Section 13, “Policy Administration”, contains details about the owner and other key roles in relation to this Policy, as well as information about how and when this Policy is reviewed and updated.

2. Data Controller

In relation to this Policy and any Personal Data processed, the data controller is ETC Management Limited, whose details are below:

ETC Management Ltd
Gridiron, One Pancras Square
London, N1C 4AG
United Kingdom

ETC Management Limited is registered with the Information Commissioner’s Office in the United Kingdom, under registration number ZA820221. Its current registration runs until 30 November 2021.

3. Principles and Practices of Personal Data Processing

3.1 Data Protection Principles

We will comply with data protection law, including the DPA 2018 and the applicable provisions of the GDPR. This says that the Personal Data we hold about you must be:

3.2 Categories of your Personal Data and purposes of our processing

For anyone other than staff members (staff members, please see section 10 and the Data Protection Notice referred to there), the following categories of your Personal Data will be processed for the purposes described in the following use cases:

3.3 Legal basis for our processing of your Personal Data

Our processing of your Personal Data is allowed by applicable law. The particular legal bases are:

3.4 Do you have to provide your Personal Data to us?

The provision of your Personal Data is necessary to make direct contact with us, or to receive a newsletter, or to process a redemption request or in some cases to do business with ETC. Although you are obliged to provide your Personal Data to us as part of these activities, the consequences if you do not want to provide your Personal Data to us are that the respective service offered may no longer be available, or you will not be able to access certain sections of our website or ETC may not be able to process your redemption request or do business with you or the organisation you represent.

3.5 Do we make automated decisions on you?

We do not make any automated decisions solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

3.6 Retention periods

The period for which your Personal Data will be stored by us is shown below:

4. Transfer of Personal Data to Third Parties

Generally, we will not transfer your Personal Data to third parties except such transfer is permitted by law or you have explicitly consented to the transfer. We may transfer your Personal Data to public authorities where this is required by the applicable law. A transfer of your Personal Data is also permitted if there is a suspicion of a criminal offence or the abuse of the services offered on our website. In this event, we shall be entitled to transfer your Personal Data to the criminal prosecution authority. Otherwise, your personal data will be stored exclusively in our database and on our servers, or on those of our commissioned data processing providers. We will only share your Personal Data with other controllers for their own purposes such as cooperation or advertising partners under the condition that you explicitly and voluntarily agreed to such transfer of your Personal Data; in this case, we will obtain your consent separately from this Policy.

5. Data retention period

Unless a longer retention period is required or permitted by applicable law, your Personal Data will only be stored for the period necessary to fulfil the purposes outlined in this Policy or until you request that your Personal Data be deleted.

6. Links to third-party websites

Our website may, from time to time, provide links to external websites. We do not have control over such websites and are not responsible for the content of these websites. ETC does not take responsibility for the data privacy policies of external websites, and this Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement about privacy of other websites prior to using them.

7. Advertising

The advertising published on our website may be based on cookies placed on your computer, in order to adjust advertising for products and services based on your individual interests. These cookies collect data on the utilization of the websites in anonymized form and do not permit profiling which is not anonymized. You can inactivate the cookie option in your browser.

8. Use of Cookies

We use two types of cookies to provide a pleasant online experience with our website: technically required cookies, without which the functionality of our website would be limited, and optional cookies to enhance user-friendliness. It is important to us that users can easily access the information provided by us. We therefore strive to continuously improve and develop our website. Cookies help us achieve this objective.
At the same time, the protection of your privacy is of utmost importance to us. We handle personal data very carefully and would therefore like to inform you in detail which cookies we use for which purpose.

Required cookies: These cookies are necessary to ensure the smooth functioning of this website (e.g. session cookies, cookie to store the selected cookie preferences, etc.). These required cookies can therefore not be deactivated.

Optional cookies: Functional cookies are used to ensure the smooth functioning of all tools on the website. The entire and proper function of the website is available to the user only with the use of functional cookies. The use of analysis cookies serves the ongoing quality improvement of this website and its content. By using them, we aim to maximise user satisfaction.

You may enable or disable cookies in your browser. By default, most browsers accept cookies but this can be changed. For further details, please visit the help section of your browser. You can choose to delete cookies at any time; however you may lose information that enables you to access the website more quickly and efficiently including, but not limited to, personalization settings.

It is recommended that you ensure that your browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure about adjusting your privacy settings.

9. Your Rights

Under applicable data protection laws, you have rights

To the extent our processing of your Personal Data is based on your consent, you also have the right to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal. To exercise your rights, you can contact us as set out in section 2. You can also lodge a complaint about our processing of your Personal Data with a data protection authority.

10. Ancillary Documents

We may from time to time introduce more detailed procedures, or other ancillary documents to support this Policy. Those ancillary documents will always be consistent with the principles in this Policy. Currently, the only such ancillary document in place is a Data Protection Notice which we provide to new recruits (either as part of the recruitment process, when making a job offer, or as of their start date) that describes how we process Personal Data of our staff members.

11. Training and awareness

All personnel are made aware of data protection and privacy laws and are trained annually in relation to these laws and this Policy.

12. Definitions

In this Policy document, we use various abbreviations and terms with initial capital letters, which have the following meanings:

Term Meaning
Data Protection Notice The notice prepared by ETC for staff members, made available to candidates and new hires, and generally available to staff
DPA 20188 Data Protection Act 2018 (UK)
GDPR General Data Protection Regulation EU 2016/679
Personal Data As defined for purposes of DPA 2018 and GDPR, but effectively any information about an individual from which that person can be identified; it does not include data where the identity has been removed (anonymous data)
Policy The current approved version of this document, “Privacy Policy” (including, where the context requires, the Procedures or any supporting documentation)
Policy Admin As determined by the Policy Owner from time to time; currently the General Counsel
Policy Owner The board of directors of ETC Management Ltd

13. Policy Administration

The entity with overall responsibility and oversight for this Policy is the Policy Owner. The Policy Owner will formally review this Policy at least annually (scheduled for review in the fourth quarter), or more frequently, where circumstances require. The Policy Admin may approve non-material changes to this Policy document between regular Policy Owner reviews, so long as such changes are endorsed by the Policy Owner at its next regular review. The Policy Admin may, in its discretion, refer any questions or matters of interpretation in relation to this Policy up to the Policy Owner.

The version history of this Policy is set out in the table below. The table will be updated each time a new version is approved.

Version Remarks Date
1.0 Initial adoption of Policy 2020
1.1 Regular annual review by Policy Owner; Updating of Policy document to conform to Group style, addition of Data Protection Notice for staff January 2021
1.2 Non-material updates, initiated by Policy Admin, to address additionally identified use cases (direct redemptions and KYC), to be endorsed by Policy Owner at next regular review March 2021

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